RISK-Matrix WAGES AND BENEFITS

HIGH RISK
Must compensate all workers with wages, overtime premiums, and benefits that meet or exceed legal standards or collective agreements, whichever are higher Must provide all legally mandated holidays, leave, benefits and bonuses Workers should be provided with pay slips in a language the workers understand that shows regular and overtime hours worked, regular and overtime rates and wages, bonuses and deductions. Wages paid on time on a monthly basis

INTERMEDIATE RISK

WORK HOURS
7th day of rest guaranteed Regular and overtime hours within legal & Code of Conduct limits Overtime is voluntary Shall provide reasonable meal and rest breaks, which at a minimum is compliant with the law

CHILD LABOR
Valid age documentation maintained for all employees Children under the minimum working age (18) should not be allowed in factory work areas at any time.

RESTRICTED OR FORCED LABOR

All forms of forced and slave labor are prohibited.

Original documents (birth cert., official ID card, passport) are not retained by facility. Employer retention of docs w/employee permission but ees cant access docs

ABUSE, DISCRIMINATION & OTHER HUMAN RIGHTS FINDINGS

No Physical or verbal abuse No Corporal Punishment No Prison Labor utilized No Discrimination (gender, race, religion, etc.) No Frisking by opposite sex

FREEDOM OF ASSOCIATION

must respect the right of workers to choose whether to lawfully and peacefully form or join trade unions or similar means of their choosing and to bargain collectively

SUBCONTRACTORS
Home workers w/no records, no monitoring Home workers w/records and monitoring visits Home worker network fully documented, all records maintained, with monitoring and training program in place. All wages, benefits provided. No subcontractors or home workers used

Intentional nondisclosure of sub contractors

Disclosure of unapproved subcontractors producing goods for the client

DOCUMENTATION (Labor, General, Licenses & Quota)

Missing legally required labor contracts Employees not given a copy of their contract (willfully to avoid legally entitled benefits) No I-9 forms or numerous (over 10%) missing I-9 forms (U.S. only) Failure to meet terms of required labor contract Employees not given a copy of their contract or provided later after hire (clerical oversight) Labor contracts not signed by the employee or approved by the government (if required by law) Breech of probation period limits or terms Complies with all local labor law regulations

Inspection Denied; Any part of the inspection denied or documents refused Missing legally required licenses or shipping visas or environmental permits
(Note: CSCC only conducts country of origin/quota inspections as part of a social compliance audit in Vietnam as of 1/1/05)

Any missing requested documentation (not refused) to support audit findings Legally required postings not posted

Probation period is clear to employees and employee becomes permanent per country law when period ends. All components of audit allowed All requested documentation provided All licenses, shipping visas, quota documentation and environmental permits appear to current and valid No evidence of transshipment found All country of origin documentation present

Incorrect country of origin paperwork/labels

- Cut labels; - Some missing country of origin documentation - No country of origin paperwork (but no evidence of transshipment found during walk through)

IMPORTED WORKER ISSUES

Only Receiving Country Issues Cited as Findings Factory charged deposits or debt bonds as a condition of employment upon arrival in receiving country (deducted from wages or in lump sum; this would be deposits, or deductions in addition to those paid in the home country) Labor contracts inconsistent with imported worker testimonies with regards to wages, deposits or other arrangements; Falsified labor contracts Management holds imported workers original passports with or without their consent Termination of employment contract and employee sent home for becoming pregnant Restriction of movement outside the factory on their day(s) off No extra deposits charged by the factory in addition to what the home/sending country agent/broker charged

Sending Country Agent/Broker Hiring Criteria Gathered as Information Only

Imported workers not given a copy of the their labor contracts; Labor contracts not signed by employees;

Labor contracts reflect actual hiring practices, do not infringe upon workers rights are signed by the employee with a copy provided to them Employees are allowed to keep their own original identification/travel documents or have complete and free access to original documents at all times No pregnancy testing or questions upon arrival or during employment tenure Employees are free to leave the factory or dormitory during their days off and after working hours No human rights abuses detected for imported workers

Pregnancy testing or questioning upon arrival or during tenure of employment

Curfews or electricity shutoffs for dormitories of imported workers Any human rights abuses targeted at imported workers versus local workers (excessive hours, uncompensated and/or forced overtime, discrimination, harassment and abuse, unfair or overly harsh disciplinary measures Other Illegal terminations or threats of repatriation

Employees work in threat-free work environment without fear of illegal termination No health and safety training; No training records maintained; Insufficient safety training Employees not issued PPE (lower exposure to hazardous materials); Use of PPE not enforced by supervisors; Insufficient/ incorrect PPE Missing first aid kits or supplies No first aid supplies or personnel No accident or injury record No legally required clinic; Inappropriate needle disposal; Records not maintained or insufficient; No or incorrect medical waste management No copies of doctor or nurse certifications Missing some equipment; Most of equipment improperly labeled expired or blocked Exits temporarily blocked. No/ missing exit signs or lights Emergency door not open outward, Employee are too far from any emergency exit Employees and supervisors trained in first aid, evacuation drills and use of fire equipment; Occupational H&S training provided and records available Required PPE issued to employees and consistently used by them

HEALTH & SAFETY (Factory) Employee Training

Falsified training records

PPE

No PPE and employees have direct contact with high volume hazardous material (Example: Spray painting without local ventilation and respirator)

First Aid Records Clinic

Excessive serious recent accidents (loss of body part, etc.) Medical personnel not qualified

Well stocked first aid kits provided in all areas for every 100 employees Accident or injury record maintained Legally required clinic maintained on-site; Qualified medical personnel provide reputable medical care; Proper needle disposal maintained Detailed medical records maintained; Proper medical waste management Adequate number of functional fire equipment Equipment properly labeled and mounted All areas have at least 2 unlocked, easily accessible exits that open outward and are marked by exit signs and emergency lights

Fire Safety Emergency Exits

No fire equipment (pervasive); Majority are non-functional No secondary exits (pervasive) Exits locked (pervasive)

Emergency Pathways

Noise Lighting Ventilation Maintenance Machine Safety Electrical Safety

Oppressive temperatures -- heat/cold Hazardous material, e.g. dust/ chemical, workstation without local ventilation Observable structural flaws which present a serious hazard to employees No machine safety equipment (pervasive) Dangerous equipment (Pressing machine with out protective equipment) Exposed wiring or panel nearby workers (immediate hazard to workers)

Blocked/ congested/ narrow aisles, Aisle not directly leading to emergency exit Yellow evacuation lines not painted on Noise unmonitored; Earplugs not provided; Work more than 8 hours under 85 dB Illumination insufficient for intricacy of work Ventilation insufficient or inadequate

Work floors marked with yellow lines leading toward the exit, all aisles and work stations clear of obstructions and allowing easy movement Employees not subject to noise louder than 85 Dbl for 8 hours Illumination sufficient Ventilation sufficient and temperatures controlled Facility appears to be well cared for and in safe condition All machine safety devices are installed on machines Electrical cords are in safe condition; Electrical panels are covered and labeled

Chemical and Hazardous materials

Chemicals released directly into the environment. Immediate hazard to employees

MSDS

Restrooms

No restrooms on premises available

Kitchen/Canteen

Severe vermin or insect infestation or severely unsanitary; Improper/unsanitary handling or storage of food by cafeteria workers

Facility not maintained to local standards. Serious uneven or broken floor/ structure Some machine safety equipment missing. No/ missing pulley guard on sewing machine or other similar machinery. Electrical panels not labeled; Panels not covered; Exposed and/or dangerous electrical wiring; Tripping or overhead hazard; Not three prong grounded or Not one length continuous wiring No secondary containment, Chemicals not covered, labeled No separate/ designated chemical storage areas Inadequate electricity fixture or ventilation in chemical storage No/ missing MSDS MSDS not posted in chemical use or storage areas Not in local language No MSDS training/ training record Restrooms not sanitary No supplies provided Missing supplies (TP, soap, paper hand towels) Insufficient in number Poor ventilation or illumination No privacy inside Not separated by gender No secondary exit; No exit lights or signs; No fire equipment; No first aid kit; Missing or non functional refrigerator; No health license or employee certification (if law requires) Soap not provided to wash plates, utensils, etc. Unsanitary conditions (not severe)

Chemicals stored in a dedicated chemical storage area with a fire door, fire extinguishers, secondary containment etc.

MSDS maintained and posted in chemical storage and use areas

Restrooms separated by gender, have privacy stalls, are sufficiently sanitary, well illuminated and ventilated, provided with clean running water, toilet paper, soap, paper hand towels and cleaned at least daily

Canteen has sufficient seating for all employees, is sanitary, has a functional refrigeration unit and equipped with fire extinguishers, exit signs and emergency lights; food properly handled; health license and employee certification maintained (if required by law)

ENVIRONMENT (Factory) Hazardous waste management

Direct discharge to environment Missing or expired legally required permits or licenses

Hazardous waste not separated from regular waste

Proper hazardous waste management with all required permits and/or licenses appearing to be current and valid

Air emissions Water emissions Trash/Dumping DORMITORIES Living Conditions

Pollutant is directly discharged into environment Pollutant is directly discharged into environment

Waste treatment facility but lack of certificate or passed sample test result Waste treatment facility but lack of certificate or passed sample test report Trash dumped into open outside area (not controlled) Inadequate building conditions No attached handrails in stairwells Inadequate lighting and temperature Licenses and/or permits to install the dormitories have not been obtained Inadequate fire equipment Missing some fire equipment Fire equipment is not marked, is not accessible, and is not serviced Evacuation routes are not designated and marked or ees are too far from 1 or both exits Evacuation and fire training is not provided Emergency lights are not installed Evacuation plot plan is not implemented No first aid kits implemented First aid kits not stocked or locked Electrical control panels not labeled or blocked or exposed. Exposed wiring Unsanitary conditions in restrooms; Restrooms are not stocked with running water, and supplies; Restrooms/Showers are not separated by gender; Inadequate number of restrooms; Potable water is not available; No privacy in toilets/showers; No hot water available for bathing; Inadequate/ poor ventilation Incomplete or not clean kitchen/food preparation area; No license/ employee no health cert. (if legal requirement); No refrigerator, improper food storage, food on floor; Cooked food is not covered; Cooked food and raw food not separated Curfew with no disciplinary actions; Inadequate security guards behavior; Inadequate information to employees in regards of dormitories rules; Inadequate number of populace in one room; Dormitories are not separated by gender

Proper waste treatment facility with certificate and passed sample test report (if applicable) Proper waste treatment facility with certificate and passed sample test report (if applicable) Outside environment is free of trash and is maintained in good condition Structure provides adequate shelter Handrails installed in stairwells and applicable passages Building is well lit All licenses are in place Fire equipment is available, accessible, marked and serviced. Evacuation routes are properly marked and accessible Evacuation and fire training is provided twice a year Emergency lights are installed Evacuation plot plan is posted

Egregious hazardous building conditions The dormitories are located near or where explosive, inflammable or combustible material is handled or stored No fire equipment No secondary evacuation exit or route No fire alarm installed

Health and Safety in housing

Egregious electrical hazardous conditions Stocked first aid kits available Electrical control panels accessible and marked

Ventilation and Sanitation

No toilets available; Open sewage in the housing location Severe vermin or insect infestation

Restrooms and showers are in acceptable sanitary conditions; Facilities are stocked with supplies and running water; Adequate number of restrooms and showers; Drinking water is available at all times

Kitchen/ Canteen

No fire equipment in kitchen; No secondary exit or insufficient secondary exit Unsanitary food preparation or eating area

Kitchen area is clean and provides refrigeration unit, and table ware, fire equipment, maintains proper food storage and health license and certifications (if required)

Human Rights

Curfew disciplinary actions; Electricity shut off to enforce curfew; Personal liberties are not respected; Illegal or excessive deductions for housing; Excessive and abusive security policies implemented; Excessive populace in one room;

No curfew is implemented; Security guards respect employees personal liberties; Employees are informed properly of housing accommodations rules, cost and conditions; Adequate populace designated in each dormitory; Dormitories are gender separated;

Employees are not free to find independent housing if desired; Employer restricts the freedom of meetings; Standards of dormitories vary according to the race or ethnic background of the workers

Employer respects the freedom of employees meetings within the promises